Testimony 

Before the Subcommittee on Oversight 

and Investigations, Committee on Energy 

and Commerce, House of Representatives 

United States General Accounting Office 

GAO

For Release on Delivery 

Expected at 9:30 a.m. EDT, 

Thursday, July 17, 2003 NUCLEAR WASTE 

Challenges and Savings 

Opportunities in DOE's 

High-Level Waste Cleanup 

Program 

Statement of Robin M. Nazzaro, Director 

Natural Resources and Environment 

GAO-03-930T 
DOE’s initiative for reducing the costs and time required for cleanup of 

high-level wastes is still evolving. DOE’s main strategy for treating high-level 

waste continues to include separating and concentrating much of the 

radioactivity into a smaller volume for disposal in a geologic repository. 

Under the initiative, DOE sites are evaluating other approaches, such as 

disposing of more waste on site. DOE’s current savings estimate for these 

approaches is $29 billion, but the estimate may not be reliable or complete. 

For example, the savings estimate does not adequately reflect uncertainties 

or take into account the timing of when savings will be realized. 

DOE faces significant legal and technical challenges to realize these 

savings. A key legal challenge involves DOE’s process for deciding that 

some waste with relatively low concentrations of radioactivity can be 

treated and disposed of on-site. A recent court ruling invalidated this 

process, putting the accelerated schedule and potential savings in jeopardy. 

A key technical challenge is that DOE’s approach relies on laboratory testing 

to confirm separation of the waste into high-level and low-activity portions. 

At the Hanford Site in Washington State, DOE plans to build a facility before 

conducting integrated testing of the waste separation technology—an 

approach that failed on a prior major project. 

DOE is exploring proposals, such as increasing the amount of high-level 

waste in each disposal canister, that if successful could save billions 

of dollars more than the current $29 billion estimate. However, considerable 

evaluation remains to be done. DOE also has opportunities to improve 

program management by fully addressing recurring weaknesses GAO has 

identified in DOE’s management of cleanup projects, including the practice 

of incorporating technology into projects before it is sufficiently tested. 

Waste Storage Tanks under Construction at DOE’s Hanford Site, September 1947 

Many of the waste storage tanks, such as those above, were built in the 1940s to 1960s. These 

tanks, now underground, are used to store high-level waste and have exceeded their design life of 

10-40 years. Some have leaked waste into the soil. 

The Department of Energy (DOE) 

oversees the treatment and 

disposal of 94 million gallons of 

highly radioactive nuclear waste 

from the nation’s nuclear weapons 

program, currently at DOE sites in 

Washington, Idaho, and South 

Carolina. In 2002, DOE began an 

initiative to reduce the estimated 

$105-billion cost and 70-year time 

frame of this cleanup. GAO was 

asked to testify on the status of this 

initiative, the legal and technical 

challenges DOE faces in 

implementation, and any further 

opportunities to reduce costs or 

improve program management. 

GAO’s testimony is based on a 

report (GAO-03-593) released at the 

hearing. 

GAO made recommendations in the 

report on which this testimony is 

based. In commenting on the 

report, DOE agreed to consider 

seeking clarification from the 

Congress about its authority to 

decide that waste with low 

concentrations of radioactivity 

could be treated and disposed of 

on-site. DOE disagreed with the 

need to conduct integrated testing 

of the Hanford waste separation 

technology and argued that its 

existing actions are sufficient to 

support decision making with 

rigorous analysis, test new 

technology before incorporating it 

into projects, and pursue 

concurrent design/construction of 

complex facilities. GAO disagrees 

and continues to believe that its 

recommendations are warranted. 

www.gao.gov/cgi-bin/getrpt?GAO-03-930T 

To view the full product, click on the link 

above. For more information, contact Robin 

M. Nazzaro at (202) 512-3841 or 

nazzaror@gao.gov. 

Highlights of GAO-03-930T, a testimony 

before the Subcommittee on Oversight 

and Investigations, Committee on Energy 

and Commerce, House of Representatives 

July 17, 2003 

NUCLEAR WASTE

Challenges and Savings Opportunities in 

DOE’s High-Level Waste Cleanup 

Program 
Page 1 GAO-03-930T High-Level Waste Cleanup 

Mr. Chairman and Members of the Subcommittee: 

We are pleased to be here today to discuss the Department of Energy’s 

(DOE) high-level waste cleanup program. DOE has about 94 million 

gallons of highly radioactive nuclear waste from the nation’s nuclear 

weapons program. This waste is currently in temporary storage at DOE 

sites in Washington, South Carolina, and Idaho. After investing more than 

20 years and about $18 billion, DOE acknowledged in February 2002 that 

the program to clean up its high-level waste was far behind schedule, far 

over budget, and in need of major change. In 2002, DOE began an initiative 

to reduce the program’s nearly $105-billion estimated cost and 70-year 

time frame to finish permanent disposal of this waste. Our testimony, 

based on work included in the report being released by the Subcommittee 

today,1

 discusses (1) the components of DOE’s high-level waste and the 

process involved in preparing the waste for disposal, (2) the status of 

DOE’s accelerated cleanup initiative for high-level waste, (3) legal and 

technical challenges DOE faces in implementing the initiative, and (4) 

further opportunities to reduce costs beyond those identified in DOE’s 

current cost-savings proposal or to improve program management. 

In summary, we found the following: 

• DOE’s high-level waste has many components, ranging from 

radioactive isotopes and corrosive chemicals to the water in which 

much of this material was initially discharged. The radioactive 

components vary greatly; a small portion will remain dangerously 

radioactive for millions of years, while the vast majority will lose much 

of their radioactivity more quickly, so that more than 90 percent of the 

current radioactivity will be gone within 100 years. To prepare the 

waste for permanent disposal, DOE plans to separate the waste into 

two waste streams: one with high levels of radioactivity and the other 

with lower concentrations of radioactivity. DOE expects that this 

process will concentrate at least 90 percent of the radioactivity into a 

volume that is significantly smaller than the current total volume of 

waste. DOE plans to immobilize and bury the highly radioactive portion 

in a permanent underground repository. The remaining waste will be 

immobilized and disposed of at the location where it is currently stored 

or at some other location. 

 1

U.S. General Accounting Office, Nuclear Waste: Challenges to Achieving Potential 

Savings in DOE’s High-Level Waste Cleanup Program, GAO-03-593 (Washington, D.C.: 

June 17, 2003). 
Page 2 GAO-03-930T High-Level Waste Cleanup 

• DOE’s initiative to accelerate the cleanup is evolving, and while its 

savings estimates are changing accordingly, we have ongoing concerns 

about the reliability of those estimates. As of April 2003, DOE 

estimated it could shorten the waste cleanup schedule by 20-35 years 

and save up to $29 billion. To help achieve these schedule and cost 

reductions, DOE has identified alternative treatment and disposal 

strategies, such as developing ways to permanently dispose of more of 

the radioactive waste at current sites rather than moving it to the 

planned underground repository. However, our assessment of DOE’s 

savings estimate indicates that it may not be reliable. For example, the 

savings analysis does not take into account all costs associated with 

alternative treatment strategies. Also, the estimate of savings does not 

compare costs on the basis of “present value,” where dollars to be 

saved in future years are discounted to a common year to reflect the 

time value of money. At DOE’s Savannah River Site in South Carolina, 

such an adjustment would lower the savings estimate for accelerated 

waste processing by $2.6 billion—from $5.4 billion to $2.8 billion (in 

2003 dollars). 

• DOE faces significant legal and technical challenges to realize the 

estimated savings. A key legal challenge involves DOE’s authority to 

apply a designation other than high-level waste to some waste with 

relatively low concentrations of radioactivity, so that this portion can 

be treated less expensively than highly radioactive waste. A recent 

court ruling invalidated this redesignation process, thus precluding 

DOE from proceeding with this element of its accelerated initiative. If 

DOE cannot meet its accelerated schedules, then potential savings are 

in jeopardy. A key technical challenge is that DOE’s approach relies 

primarily on laboratory testing to confirm that separating waste into 

high-level and low-activity portions will be successful. At the Hanford 

Site in Washington State, DOE is planning to construct full-scale 

facilities before fully testing the technologies on an integrated basis—

an approach that has failed on another project in the past, resulting in 

significant cost increases and schedule delays. 

• DOE is exploring additional cost savings beyond those identified in its 

current cost-saving proposals. The proposals that offer significant 

potential are being developed by the Hanford and Savannah River sites. 

These proposals call for increasing the amount of waste that can be 

concentrated into the canisters destined for the permanent 

underground repository. DOE’s data indicates that these proposals, if 

successful, could save several billion dollars. Considerable evaluation 

of these proposals remains to be done and cost-saving estimates have 
Page 3 GAO-03-930T High-Level Waste Cleanup 

not yet been fully developed, according to DOE officials. DOE also has 

opportunities to improve its management of the cleanup program by 

addressing management weaknesses that we and others have identified 

in the past. Although DOE has taken steps to improve program 

management, we have continuing concerns about management 

weaknesses in several areas. These include making key decisions 

without rigorous supporting analysis, incorporating technology into 

projects before it is sufficiently tested, and pursuing a “fast-track” 

approach of launching into facility construction before completing 

sufficient design work. It does not appear that DOE’s current 

management efforts will fully address these weaknesses. 

Our report makes several recommendations to DOE that, if implemented, 

will help to manage or reduce legal and technical risks to the program, 

avoid costly delays, and strengthen overall program management. DOE 

agreed to consider our recommendation to seek clarification from the 

Congress regarding its authority to determine that some waste can be 

treated and disposed of as other than high-level waste. However, regarding 

our recommendations that the department conduct integrated pilot testing 

of its waste separation processes at Hanford, and take steps to improve 

the management of high-level waste projects, such as by conducting more 

rigorous analyses to support key project decisions, DOE believes that its 

current approach is adequate. We do not agree with DOE’s views and 

continue to believe that all of our recommendations are warranted. 

DOE has a vast complex of sites across the nation dedicated to the nuclear 

weapons program. DOE largely ceased production of plutonium and 

enriched uranium by 1992, but the waste remains at the sites. Most of the 

tanks in which the waste is stored have already exceeded their design life. 

For example, many of Hanford’s and Savannah River’s tanks were built in 

the 1940s to 1960s and were designed to last 10-40 years. Leaks from some 

of these tanks were first detected at Hanford in 1956 and at Savannah 

River in 1959. Given the age and deteriorating condition of some of the 

tanks, there is concern that some of them will leak additional waste into 

the soil, where it may migrate to the water table and, in the case of the 

Hanford Site, to the Columbia River. 

Responsibility for the high-level waste produced at DOE facilities is 

governed primarily by federal laws, including the Atomic Energy Act of 

1954. These laws established responsibility for the regulatory control of 

radioactive materials including DOE’s high-level waste and assigned the 

Nuclear Regulatory Commission (NRC) the function of licensing facilities 

Background 
Page 4 GAO-03-930T High-Level Waste Cleanup 

that are expressly authorized for long-term storage of high-level 

radioactive waste generated by DOE. In addition, the Nuclear Waste Policy 

Act of 1982 defined high-level radioactive waste. Various other federal 

laws, including the Resource Conservation and Recovery Act of 1976, 

guide how DOE must carry out its cleanup program. The high-level waste 

cleanup program is under the leadership of the Assistant Secretary for 

Environmental Management. It involves consultation with a variety of 

stakeholders, including the Environmental Protection Agency, state 

environmental agencies where DOE sites are located, county and local 

governmental agencies, citizen groups, advisory groups, and Native 

American tribes. 

The waste in the tanks at the Hanford and Savannah River sites and the 

Idaho National Laboratory near Idaho Falls is a complex mixture of 

radioactive and hazardous components. DOE’s process for preparing it for 

disposal is designed to separate much of the radioactive material from 

other waste components. 

Nearly all the radioactivity in the waste originates from radionuclides with 

half-lives2

 of about 30 years or less. The relatively short half-lives of most 

of the radionuclides in the waste means that within 30 years, about 

50 percent of the current radioactivity will have decayed away, and within 

100 years this figure will rise to more than 90 percent. Figure 1 shows the 

pattern of decay, using 2002 to 2102 as the 100-year period. Extending the 

analysis beyond the 100-year period shown in the figure, in 300 years, 

99.8 percent of the radioactivity will have decayed, leaving 0.2 percent of 

the current radioactivity remaining. 

 2

Each radioactive component, or radionuclide, in high-level waste loses its radioactivity at 

a rate that differs for each component. This rate of decay, which cannot be changed, is 

measured in “half-lives”—that is, the length of time required for half of the unstable atoms 

to decay and release their radiation. 

DOE’s High-Level 

Waste Is a Complex 

Mixture That Requires 

a Multi-Step Process 

to Prepare for 

Disposal 

Much of the Radioactivity 

Declines Relatively 

Quickly 
Page 5 GAO-03-930T High-Level Waste Cleanup 

Figure 1: Natural Decay of Radionuclides in DOE’s Untreated High-Level Waste 

from 2002 to 2102 

Note: Radioactivity is measured in a unit called a curie. One curie equals 37 billion atomic 

disintegrations per second. 

Despite the relatively rapid decay of most of the current radioactivity, 

some radionuclides have half-lives in the hundreds of thousands of years 

and will remain dangerously radioactive for millions of years. Some of 

these long-lived radionuclides are potentially very mobile in the 

environment and therefore must remain permanently isolated. If these 

highly mobile radionuclides leak out or are released into the environment, 

they can contaminate the soil and water. 

DOE plans to isolate the radioactive components and prepare the waste 

for disposal through a multi-step treatment process. DOE expects this 

process to concentrate at least 90 percent of the radioactivity into a much 

smaller volume that can be permanently isolated for at least 10,000 years 

in a geologic repository. The portion of the waste not sent to the geologic 

repository will have relatively small amounts of radioactivity and 

long-lived radionuclides. Based on current disposal standards used by the 

NRC, if the radioactivity of this remaining waste is sufficiently low, it 

can be disposed of on site near the surface of the ground, using less 

Processing Can 

Concentrate the 

Radioactivity into a Much 

Smaller Volume of Waste 
Page 6 GAO-03-930T High-Level Waste Cleanup 

complex and expensive techniques than those required for the highly 

radioactive portion. DOE plans to dispose of this waste on site in vaults 

or canisters, or at other designated disposal facilities. 

DOE has successfully applied this process in a demonstration project at 

the West Valley site in New York State. At West Valley, separation of the 

low-activity portion from the high-level portion of the waste reduced by 

90 percent the quantity of waste requiring permanent isolation and 

disposal at a geologic repository. The high-level portion was stabilized in a 

glass material (vitrified) and remains stored at the site pending completion 

of the high-level waste geologic repository and resolution of other issues 

associated with disposal costs.3

 The remaining low-activity portion was 

mixed with cement-forming materials, poured into drums where it 

solidified into grout (a cement-like material), and remains stored on site, 

awaiting shipment to an off-site disposal facility. 

DOE’s new initiative, implemented in 2002, attempts to address the 

schedule delays and increasing costs DOE has encountered in its efforts to 

treat and dispose of high-level waste. This initiative is still evolving. As of 

April 2003, DOE had identified several strategies to help reduce the time 

needed to treat and dispose of the waste. Based on these strategies, DOE 

estimated that it could reduce the waste cleanup schedule by about 20 to 

35 years at its high-level waste sites and save about $29 billion compared 

to the existing program baseline.4

 While some degree of savings is likely if 

the strategies are successfully implemented, the extent of the savings is 

still uncertain. 

 3

At Savannah River, high-level sludge from the tanks has also been stabilized in glass 

material and is currently stored on site pending completion of the geologic repository. As 

of August 30, 2002, Savannah River had produced 1,331 canisters of this stabilized waste. 

4

Unless otherwise noted, all dollar estimates are as reported by DOE and are in 

current dollars. 

DOE’s Initiative for 

Accelerating Cleanup 

Is Still Evolving, with 

the Extent of Savings 

Uncertain 
Page 7 GAO-03-930T High-Level Waste Cleanup 

Many of DOE’s proposals to speed cleanup and reduce environmental risk 

involve ways to do one or more of the following: 

• Deal with some tank waste as low-level or transuranic5 waste, rather 

than as high-level waste. Doing so would eliminate the need to vitrify 

the waste for off-site disposal in the geologic repository for high-level 

waste. 

• Complete the waste treatment more quickly by using additional or 

supplemental technologies. For example, DOE’s Hanford Site is 

considering using up to four supplemental technologies, in addition to 

vitrification, to process its low-activity waste. DOE believes these 

technologies are needed to help it meet a schedule milestone date of 

2028 agreed to with regulators to complete waste processing. Without 

these technologies, DOE believes waste treatment would not be 

completed before 2048. 

• Segregate the waste more fully than initially planned and tailor waste 

treatment to each of the waste types. By doing so, DOE plans to apply 

less costly treatment methods to waste with lower concentrations of 

radioactivity. 

• Close waste storage tanks earlier than expected, thereby avoiding the 

operating costs involved in maintaining the tanks and monitoring the 

wastes. 

Table 1 summarizes the estimated cost savings for each DOE site if 

accelerated proposals for cleaning up high-level waste are successfully 

implemented. 

 5

Low-level radioactive waste is defined as radioactive material that is not high-level 

radioactive waste, spent nuclear fuel, transuranic waste, or certain by-product material 

(the tailings or wastes produced by the extraction or concentration or uranium or thorium 

from any ore processed primarily for its source material content). 42 U.S.C. 10101(16). 

Transuranic wastes come primarily from reprocessing of spent nuclear fuel and from 

fabrication of nuclear weapons. Transuranic waste is defined as waste with radionuclides 

with atomic numbers greater than 92 (that is, uranium) and having half-lives greater than 

20 years in concentrations greater than 100 nanocuries per gram. 

Initiative Centers on Ways 

to Speed Disposal and 

Save Money 
Page 8 GAO-03-930T High-Level Waste Cleanup 

Table 1: DOE’s Estimated Cost Savings from Proposals to Accelerate Cleanup of 

High-Level Waste 

Amounts are in billions of current dollars, fiscal year 2003 to the end of cleanup 

Site 

Current baseline 

lifecycle cost 

estimate

Accelerated 

lifecycle cost 

estimate 

Estimated savings 

from accelerated 

initiatives 

Idaho National Laboratory $10.07 $ 3.10 $ 6.97 

Hanford 56.19 41.67 14.52 

Savannah River 18.82 11.49 7.33 

 Totals $85.08 $56.26 $28.82 

Source: DOE. 

Note: West Valley is not included in this table because high-level waste cleanup at the site was 

essentially completed in September 2002. 

Our review indicates that DOE’s current estimate of $29 billion may not 

yet be reliable and that the actual amount to be saved if DOE successfully 

implements the alternative waste treatment and disposal strategies may be 

substantially different from what DOE is projecting. We have several 

concerns about the reliability and completeness of the estimate. These 

concerns include the accuracy of baseline cost estimates from which 

savings are calculated, whether all appropriate costs are included in the 

analysis, and whether the savings estimates properly reflect the timing of 

the savings or uncertainties. 

DOE’s current lifecycle cost baseline is used as the base cost from 

which potential savings associated with any improvements are measured. 

However, in recent years, we and others have raised concerns about the 

reliability of DOE’s baseline cost estimates. In a 1999 report, we noted that 

DOE lacked a standard methodology for sites to use in developing their 

lifecycle cost baseline, raising a concern about the reliability of data used 

to develop these cost estimates.6

 DOE’s Office of Inspector General also 

raised a concern in a 1999 review of DOE project estimates, noting that 

several project cost estimates examined were not supported or complete. 

DOE acknowledged in its February 2002 review of the cleanup program 

 6

U.S. General Accounting Office, Nuclear Waste: DOE’s Accelerated Cleanup Strategy Has 

Benefits but Faces Uncertainties, GAO/RCED-99-129 (Washington, D.C.: Apr. 30, 1999). 

Savings Estimate May Not 

Be Reliable 

Baseline Costs Are Not Fully 

Reliable 
Page 9 GAO-03-930T High-Level Waste Cleanup 

that baseline cost estimates do not provide a reliable picture of 

project costs.7

Some of DOE’s savings may be based on incomplete estimates of the costs 

for the accelerated proposals. According to Office of Management and 

Budget (OMB) guidance on developing cost estimates, agencies should 

ensure that all appropriate costs are addressed in the estimate. However, 

DOE has not always done so. For example, the Idaho National 

Laboratory’s estimated savings of up to $7 billion is based, in large part, on 

eliminating the need to build a vitrification facility to treat its waste. 

However, the waste may have to undergo an alternative treatment method 

before it can be accepted at a geological repository, and the Idaho 

National Laboratory is considering four different technologies for doing 

so. Nevertheless, DOE’s current savings estimate reflects the potential 

cost of only one of those technologies. DOE has not yet developed the 

costs of using any of the other waste treatment approaches. DOE noted 

that the accelerated lifecycle estimate could likely change depending on 

which one of the technologies is selected and the associated costs of 

treating the waste are developed. 

According to OMB guidance, agencies should ensure that the timing of 

when the savings will occur is accounted for, that uncertainties are 

recognized and quantified where possible, and that nonbudgetary impacts, 

such as a change in the level of risk to workers, are quantified, or at least 

described. We found problems in all three areas. 

• Regarding the time value of money, applying OMB guidance would 

mean that estimates of savings in DOE’s accelerated plans should 

reflect a comparison of its baseline cost estimate with the alternative, 

expressed in a “present value,” where the dollars are discounted to a 

common year to reflect the time value of money. Instead, DOE’s 

savings estimates generally measure savings by comparing dollars in 

different years. For example, the Savannah River Site estimates a 

savings of nearly $5.4 billion by reducing by 8 years (from 2027 to 2019) 

the time required to process its high-level waste. Adjusting the savings 

estimate to present value in 2003 results in a savings of $2.8 billion in 

2003 dollars. 

 7

U.S. Department of Energy, A Review of the Environmental Management Program 

(Washington, D.C.: Feb. 4, 2002). 

Estimates of Project Costs May 

Be Incomplete 

Savings Estimates Do Not 

Reflect Timing, Uncertainty, or 

Nonbudgetary Impacts 
Page 10 GAO-03-930T High-Level Waste Cleanup 

• Regarding uncertainties, in contrast to OMB guidance, the DOE savings 

estimates generally do not consider uncertainties. For example, the 

savings projected in the Idaho National Laboratory’s accelerated plan 

reflect the proposal to no longer build the vitrification facility and an 

associated reduction in operations costs. However, the savings do not 

account for uncertainties such as whether alternatives to vitrification 

will succeed and at what cost. Rather than reflecting uncertainties by 

providing a range of savings, DOE’s savings estimate is a single point 

estimate of $7 billion. 

• Regarding nonbudgetary impacts, DOE’s savings estimates generally 

do not fully assess the value of potential nonbudgetary impacts, such 

as a change in the level of risk to workers or potential effects on the 

environment. OMB guidelines recommend identification and, where 

possible, quantification of other expected benefits and costs to society 

when evaluating alternative plans. For example, the Idaho National 

Laboratory’s accelerated plan does not assess potential increases in 

environmental risk, if any, from disposing of the waste without 

stabilizing it into a vitrified form. By not assessing these benefits and 

risks to workers and the environment, DOE leaves unclear how 

important these risks and trade-offs are to choosing an alternative 

treatment approach. 

DOE faces significant legal and technical challenges in achieving the 

cost and schedule reductions proposed in its new initiative. On the legal 

side, DOE’s proposals depend heavily on the agency’s authority to apply 

a designation other than “high-level waste” to the low-activity portion 

of the waste stream, so that this low-activity portion does not have to 

be disposed of more expensively as high-level waste. The portion of DOE’s 

order setting out criteria for making such determinations has been 

invalidated in a recent court ruling. On the technical side, DOE’s proposals 

rest heavily on the successful application of waste separation methods 

that are still under development and will not be fully tested before being 

put in place. DOE’s track record in this regard has not been strong; it has 

had to abandon past projects that were also based on promising—but not 

fully tested—technologies. Either or both of these challenges could limit 

the potential savings from DOE’s accelerated cleanup initiative. 

Key Legal and 

Technical Challenges 

Could Limit Potential 

Savings from DOE’s 

Accelerated Cleanup 

Initiative 
Page 11 GAO-03-930T High-Level Waste Cleanup 

DOE has traditionally managed all of the wastes in its tanks as high-level 

waste because the waste resulted primarily from the reprocessing of spent 

nuclear fuel and contains significant amounts of radioactivity. However, 

by separating the waste into high-level and low-activity portions and 

managing the low-activity portion as something other than high-level 

waste, DOE could use less costly and less complicated treatment 

approaches. DOE has developed guidelines for deciding when waste in the 

tanks should not be considered high-level waste. In 1999, under Order 

435.1, DOE formalized its process for determining which waste is 

incidental to reprocessing (“incidental waste”), not high level waste, 

and therefore will not be sent to a geological repository for high-level 

waste disposal. This process provides a basis for DOE to treat and 

dispose of some portion of its wastes less expensively as low-level or 

transuranic wastes. 

DOE’s ability to define some waste as incidental to reprocessing, and to 

then follow a different set of treatment and disposal requirements for that 

waste, is central to its overall strategy for addressing its tank waste. For 

example, DOE planned to use its incidental waste process to manage 

about 90 percent of its 54 million gallons of tank waste at the Hanford Site 

as low-level waste, rather than process it through a high-level waste 

vitrification facility. Using that approach, most of the waste would be 

eligible for treatment and disposal on site. Such an approach would save 

billions compared to treating all of the waste as high-level waste and 

sending it for disposal in a high-level waste geologic repository. 

A recent court ruling precludes DOE from reclassifying some of its waste 

as other than high-level waste. In March 2002, the Natural Resources 

Defense Council and others filed a lawsuit challenging DOE’s authority to 

manage its wastes through its incidental waste process.8

 The plaintiffs 

alleged that DOE arbitrarily established the incidental waste determination 

process without proper regard for the law or properly establishing a 

justification for this process. A primary concern of the plaintiffs was that 

DOE would use its incidental waste process to permanently leave 

intensely radioactive waste sediments in the tanks with only minimal 

 8

Natural Resources Defense Council, Inc. v. Abraham, No. 01-CV-413 (D. Idaho, filed 

Mar. 5, 2002). The lawsuit was originally filed in January 2000 in the 9th Circuit Court of 

Appeals and was subsequently transferred to the federal district court in Idaho. The other 

parties to the lawsuit are the Snake River Alliance, the Confederated Tribes and Bands 

of the Yakama Nation, and the Shoshone Bannock Tribes. In addition, the states of 

Washington, Idaho, Oregon and South Carolina are participating as amicus curiae. 

DOE’s Accelerated 

Initiative Relies on a 

Process for Reclassifying 

Waste That the Court Has 

Ruled Invalid 
Page 12 GAO-03-930T High-Level Waste Cleanup 

treatment. The lawsuit alleged that DOE’s incidental waste process 

improperly allows DOE to reclassify high-level waste as incidental waste 

that does not need to be treated in the same way as high-level waste. 

According to the plaintiffs, the Nuclear Waste Policy Act defines all waste 

originating from a given source—that is, from reprocessing of spent 

nuclear fuel—as high-level waste and requires that such waste be managed 

as high-level waste, yet DOE has chosen to differentiate its wastes 

according to the level of radioactivity and manage them accordingly. In a 

July 3, 2003 ruling on the lawsuit, the court agreed with the plaintiffs, 

stating that the portion of DOE’s Order 435.1 setting out its incidental 

waste determination process violates the Nuclear Waste Policy Act and 

thus is invalid. 

The court’s ruling could seriously hinder DOE’s efforts to implement its 

accelerated treatment and disposal strategies. Under the ruling, DOE’s 

incidental waste determinations cannot be implemented. Since the start of 

the lawsuit, DOE had not implemented any of its approved incidental 

waste determinations and had not yet decided whether to defer or proceed 

with its pending incidental waste determinations—such as those for 

closing tanks at the Savannah River Site and Idaho National Laboratory. 

If DOE appeals the court ruling, a lengthy legal process could follow. A 

lengthy legal process will also likely delay treatment plans for this waste 

and delay closing tanks on an accelerated schedule. For example, the 

Idaho National Laboratory planned to begin closing tanks in the spring of 

2003, pending approval of an incidental waste determination that would 

allow DOE to close the tanks by managing tank waste residuals as lowlevel waste.9

 A DOE official at the Idaho National Laboratory told us that 

while a delay of several months would not immediately threaten schedule 

dates, a delay beyond 24 months would seriously affect the site’s ability to 

meet its accelerated 2012 date to close all of the tanks. 

If the court’s ruling invalidating DOE’s incidental waste determination 

process is upheld, DOE may need to find an alternative that would allow it 

to treat waste with lower concentrations of radioactivity less expensively. 

Searching for such an alternative could delay progress at all three of 

DOE’s high-level waste sites that rely on incidental waste determinations. 

If DOE cannot meet its accelerated schedules, then potential savings are

 9

Tank closure at the Idaho National Laboratory is also pending completion of its National 

Environmental Policy Act process. 
Page 13 GAO-03-930T High-Level Waste Cleanup 

in jeopardy. At this point, the department does not appear to have a 

strategy to avoid the potential effects of challenges to its incidental waste 

determination authority, either from the current court ruling or future 

challenges. At the time of our report, DOE officials told us that they 

believed the department would prevail in the legal challenge. DOE 

believed it would be premature to explore alternative strategies to 

overcome potentially significant delays to the program that could result 

from a protracted legal conflict or from an adverse decision. Such 

strategies could range from exploring alternative approaches for 

establishing an incidental waste regulation to asking that the Congress 

provide legislative authority for DOE to implement an incidental 

waste policy. 

Like the ability to determine that some waste is incidental to reprocessing, 

the ability to separate the waste components is important to meet waste 

cleanup schedule and cost goals. If the waste is not separated, all of it—

about 94 million gallons—may have to be treated as high-level waste and 

disposed of in the geological repository. Doing so would require a much 

larger repository than currently planned, and drive up disposal costs 

by billions of dollars. Successful separation will substantially reduce the 

volume of waste needing disposal at the planned repository, as well as the 

time and cost required to prepare it for disposal, and allow less expensive 

methods to be used in treating and disposing of the remaining lowactivity waste. The waste separation process is complicated, difficult, and 

unique in scope at each site. The waste differs among sites not only in 

volume but also in the way it has been generated, managed, and stored 

over the years. 

The challenge to successfully separate the waste is significant at the 

Hanford Site, where DOE intends to build a facility for separating the 

waste before fully testing the separation processes that will be used. The 

planned laboratory testing includes a combination of pilot-scale testing of 

major individual processes and use of operational data for certain of those 

processes for which DOE officials said they had extensive experience. 

However, integrated testing will not be performed until full-scale facilities 

are constructed. DOE plans to fully test the processes for the first time 

during the operational tests of the newly constructed facilities. 

This approach does not fully reflect DOE guidance, which calls for 

ensuring that new or complex technology is mature before integrating it 

into a project. Specifically, DOE’s Project Management Order 413.3 

requires DOE to assess the risks associated with technology at various 

Accelerated Initiative Also 

Relies on Waste Separation 

Approaches That Will Not 

Be Fully Tested 
Page 14 GAO-03-930T High-Level Waste Cleanup 

phases of a project’s development. For projects with significant technical 

uncertainties that could affect cost and schedule, corrective action plans 

to address these uncertainties are required before the projects can 

proceed. In addition, DOE’s supplementary project management guidance 

suggests that technologies be developed to a reasonable level of maturity 

before a project progresses to full implementation to reduce risks and 

avoid cost increases and schedule delays. The guidance suggests that DOE 

avoid the risk of designing facilities concurrently with 

technology development. 

The laboratories working to develop Hanford’s waste separation process 

have identified several technical uncertainties, which they are working to 

address. These uncertainties or critical technology risks include problems 

with separating waste solids through an elaborate filtration system, 

problems associated with mixing the waste during separation processes, 

and various problems associated with the low-activity waste evaporator. 

Given these and other uncertainties, Hanford’s construction 

contractor and outside experts have seen Hanford’s approach as 

having high technical risk and have proposed integrated testing during 

project development. However, DOE and the construction contractor 

eventually decided not to construct an integrated pilot facility and instead 

to accept a higher-risk approach. DOE officials said they wanted to avoid 

increasing project costs and schedule delays, which they believe will result 

from building a testing facility. Instead, Hanford officials said that they will 

continue to conduct pilot-scale tests of major separation processes. DOE 

officials said they believe this testing will provide assurance that the 

separation processes will function in an integrated manner. After the fullscale treatment facilities are constructed, DOE plans to fully test and 

demonstrate the separation process during facility startup operations. 

The consequences of not adhering to sound technology development 

guidelines can be severe. At the Savannah River Site, for example, 

DOE invested nearly $500 million over nearly 15 years to develop a waste 

separation process, called in-tank precipitation, to treat Savannah River’s 

high-level waste. While laboratory tests of this process were viewed as 

successful, DOE did not adequately test the components until it started 

full-scale operations. DOE followed this approach, in part, because the 

technology was commercially available and considered “mature.” 

However, when DOE started full-scale operations, major problems 

occurred. Benzene, a dangerously flammable byproduct, was produced in 

large quantities. Operations were stopped after DOE spent about 

$500 million because experts could not explain how or why benzene was 
Page 15 GAO-03-930T High-Level Waste Cleanup 

being produced and could not determine how to economically reconfigure 

the facility to minimize it. Consequences of this technology failure 

included significant cost increases, schedule delays, a full-scale waste 

separation process that did not work, and a less-than-optimum waste 

treatment operation. Savannah River is now developing and implementing 

a new separation technology at an additional cost of about $1.8 billion and 

a delay of about 7 years.10

Subsequent assessments of the problems that developed at Savannah 

River found that DOE (1) relied on laboratory-scale tests to demonstrate 

separation processes, (2) believed that technical problems could be 

resolved later during facility construction and startup, and (3) decided to 

scale up the technology from lab tests to full-scale without the benefit of 

using additional testing facilities to confirm that processes would work at 

a larger scale. Officials at Hanford are following a similar approach. 

Several experts with whom we talked cautioned that if separation 

processes at Hanford do not work as planned, facilities will have to be 

retrofitted, and potential cost increases and schedule delays would be 

much greater than any associated with integrated process testing in a 

pilot facility. 

In addition to the potential cost savings identified in the accelerated 

site cleanup plans, DOE continues to develop and evaluate other proposals 

to reduce costs but is still assessing them. Although the potential cost 

savings have not been fully developed, they could be in the range of 

several billion dollars, if the proposals are successfully implemented. At 

the Savannah River and Hanford sites, for example, DOE is identifying 

ways to increase the amount of waste that can be placed in its high-level 

waste canisters to reduce treatment and disposal costs. DOE also has a 

number of initiatives under way to improve overall program management. 

However, we are concerned that the initiatives may not be adequate. In 

our examinations of problems that have plagued DOE’s project 

management over the years, three contributing factors often emerged—

making key project decisions without rigorous analysis, incorporating new 

technology before it has received sufficient testing, and using a “fast-track” 

approach (concurrent design and construction) on complex projects. 

 10U.S. General Accounting Office, Nuclear Waste: Process to Remove Radioactive 

Waste From Savannah River Tanks Fails to Work, GAO/RCED-99-69 (Washington, D.C.: 

Apr. 30, 1999). 

Opportunities Exist to 

Explore Additional 

Cost Savings and to 

Strengthen Program 

Management 
Page 16 GAO-03-930T High-Level Waste Cleanup 

Ensuring that these weaknesses are addressed as part of its program 

management initiatives would further improve the management of the 

program and increase the chances for success. 

DOE is continuing to identify other proposals for reducing costs under 

its accelerated cleanup initiative. Among the proposals that DOE is 

considering, the ones that appear to offer significant cost savings 

opportunities would increase the amount of waste placed in each disposal 

canister. The amount of waste that can be placed into a canister depends 

on a complex set of factors, including the specific mix of radioactive 

material combined with other chemicals in the waste, such as chromium 

and sulfate, that affect the processing and quality of the immobilized 

product. These factors affect the percentage of waste than can be placed 

in each canister because they indicate the likelihood that radioactive 

constituents could move out of the immobilizing glass medium and into 

the environment. The greater the potential for the waste to become 

mobile, the lower the allowable percentage of waste and the higher 

the percentage of glass material that must be used. 

Savannah River officials believe they can increase the amount of waste 

loaded in each canister from 28 percent to about 35 percent, and for at 

least one waste batch, to nearly 50 percent. In June 2003, Savannah River 

began to implement this new process to increase the amount of waste in 

each canister. If successful, Savannah River’s improved approach could 

reduce the number of canisters needed by about 1,000 canisters and save 

about $2.7 billion, based on preliminary estimates. Other efforts to 

increase waste loading of the canisters are also under way that, if 

successful, may permit further cost savings of about $1.7 billion. The 

Hanford Site is also exploring ways to decrease the numbers of waste 

canisters that will be needed by using waste forms other than the standard 

borosilicate glass. This effort is in a very early stage of development and 

cost-savings estimates have not been fully developed. 

DOE Is Considering 

Additional Potential 

Opportunities to Reduce 

Costs 
Page 17 GAO-03-930T High-Level Waste Cleanup 

In addition to site-specific proposals for saving time and money, DOE is 

also undertaking management improvements using teams to study 

individual issues. Nine teams are currently in place, while other teams to 

address issues such as improving the environmental review process to 

better support decision making have not yet been formed. Each team has a 

disciplined management process to follow,11 and even after the teams’ 

work is completed, any implementation will take time. These efforts are in 

the early stages, and therefore it is unclear if they will correct the 

performance problems DOE and others have identified. 

We are concerned that these management reforms may not go far enough 

in addressing performance problems with the high-level waste program. 

Our concerns stem from our review of initiatives under way in the 

management teams, our discussions with DOE officials, and our past and 

current work, as well as work by others inside and outside DOE. We have 

identified three recurring weaknesses in DOE’s management of cleanup 

projects that we believe need to be addressed as part of DOE’s overall 

review. These weaknesses cut across the various issues that the teams are 

working on and are often at the center of problems that have been 

identified. Two of these weaknesses have been raised earlier in this 

testimony—lack of rigor in the analysis supporting key decisions, and 

incorporating technology into projects before it is sufficiently mature. The 

final area of weakness involves using “fast-track” methods to begin 

construction of complex facilities before sufficient planning and design 

have taken place. 

DOE’s project management guidance emphasizes the importance of 

rigorous and current analysis to support decision making during the 

development of DOE projects. Similarly, OMB guidance states that 

agencies should validate earlier planning decisions with updated 

information before finalizing decisions to construct facilities. This 

validation is particularly important where early cost comparisons are 

susceptible to uncertainties and change. 

DOE does not always follow this guidance, yet no DOE management team 

appears to be addressing this weakness. Proceeding without rigorous 

review has been a recurring cause of many of the problems we have 

 11Under DOE’s project management principles, for example, teams must define project 

requirements, conduct preliminary risk assessments, and prepare a risk mitigation plan 

prior to developing a baseline cost estimate of proposed alternatives. 

DOE Has Opportunities to 

Improve Management of 

the Program by Addressing 

Previously Identified 

Weaknesses 

Key Decisions Not Always 

Supported by Rigorous Current 

Analysis 
Page 18 GAO-03-930T High-Level Waste Cleanup 

identified in past DOE projects. For example, the decision at Hanford to 

construct a vitrification plant to treat Hanford’s low-activity waste has not 

been validated with updated information. Hanford’s primary analysis 

justifying the cost of this approach was prepared in 1999 and was based on 

technical performance data, disposal assumptions, and cost data 

developed in the early to mid-1990s—conditions that are no longer 

applicable. Subsequent analyses have continued to rely on this data. 

However, since that time conditions have changed, including the 

performance capabilities of alternative technologies such as grout, the 

relative cost of different technologies, and the amount of waste DOE 

intends to process through a vitrification facility. 

DOE officials disagree with our assessment of their analysis, stating that a 

comprehensive analysis was conducted in the spring of 2003. However, 

DOE’s high-level waste project team agreed that the DOE officials at 

Hanford had not performed a current, rigorous analysis of low-activity 

waste treatment options including the use of grout as an alternative to 

vitrification, and the team encouraged the Hanford site to update its 

analysis based on current waste treatment and disposal assumptions. DOE 

officials at Hanford told us they do not plan to reassess the decision to 

construct a low-activity vitrification facility because their compliance 

agreement with the state of Washington calls for vitrification of this waste. 

They also stated that vitrification is a technology needed for destroying 

hazardous constituents in a portion of the waste. 

Our work on Department of Defense acquisitions has documented a set of 

“best practices” used by industry for integrating new technology into 

major projects. We reported in July 1999 that the maturity of a technology 

at the start of a project is an important determinant of success.12 As 

technology develops from preconceptual design through preliminary 

design and testing, the maturity of the technology increases and the risks 

associated with incorporating that technology into a project decrease. 

Waiting until technology is well-developed and tested before integrating it 

into a project will greatly increase the chances of meeting cost, schedule, 

and technical baselines. On the other hand, integrating technology that is 

not fully mature into a project greatly increases the risk of cost increases 

and schedule delays. According to industry experts, correcting problems 

 12U.S. General Accounting Office, Best Practices: Better Management of Technology 

Development Can Improve Weapon System Outcomes, GAO/NSIAD-99-162

(Washington, D.C.: July 30, 1999). 

New Technology Is 

Incorporated before It Is 

Sufficiently Mature 
Page 19 GAO-03-930T High-Level Waste Cleanup 

after a project has begun can cost 10 times as much as resolving 

technology problems beforehand. 

DOE’s project management guidance issued in October 2000 is consistent 

with these best practices. The guidance discusses technology development 

and sets out suggested steps to ensure that new technology is brought to a 

sufficient level of maturity at each decision point in a project. For 

example, during the conceptual design phase of a project, “proof of 

concept” testing should be performed before approval to proceed to the 

preliminary design phase. Furthermore, the guidance states that 

attempting to concurrently develop the technology and design the facility 

for a project poses ill-defined risks to the project. 

Nevertheless, as we discussed earlier, DOE sites continue to integrate 

immature technologies into their projects. For example, as discussed 

earlier, DOE is constructing a facility at the Hanford Site to separate 

high-level waste components, although integrated testing of the many 

steps in the separations process has not occurred and will not occur until 

after the facility is completed. DOE, trying to keep the project on schedule 

and within budget, has decided the risks associated with this approach are 

acceptable. However, there are many projects for which this approach 

created schedule delays and unexpected costs. The continued reliance on 

this approach in the face of so many past problems is a signal of an area 

that needs careful attention as DOE proceeds with its management reform 

efforts. At present, no DOE management team is addressing this issue. 

Finally, we have concerns about DOE’s practice of launching into 

construction of complex, one-of-a-kind facilities well before their final 

design is sufficiently developed, again in an effort to save time and money. 

Both DOE guidance and external reviews stress the importance of 

adequate upfront planning before beginning project construction. DOE’s 

project management guidance identifies a series of well-defined steps 

before construction begins and suggests that complex projects with 

treatment processes that have never before been combined into a facility 

do not lend themselves to being expedited. However, DOE guidance does 

not explicitly prohibit a fast-track—or concurrent design and 

construction—approach to complex, one-of-a-kind projects, and DOE 

often follows this approach. For example, at the Hanford Site, DOE is 

concurrently designing and constructing facilities for the largest, most 

complex environmental cleanup job in the United States. Problems are 

already surfacing. Only 24 months after the contract was awarded, the 

project was 10 months behind schedule dates, construction activities have 

outpaced design work causing inefficient work sequencing, and DOE has 

Facility Construction Starts 

before Design Is Sufficiently 

Developed 
Page 20 GAO-03-930T High-Level Waste Cleanup 

withheld performance fee from the design/construction contractor 

because of these problems. 

DOE experienced similar problems in concurrent design and construction 

activities on other waste treatment facilities. Both the spent nuclear fuel 

project at Hanford and the waste separations facility at the Savannah River 

Site encountered schedule delays and cost increases in part because the 

concurrent approach led to mistakes and rework, and required extra time 

and money to address the problems.13 In its 2001 follow-up report on DOE 

project management, the National Research Council noted that inadequate 

pre-construction planning and definition of project scope led to cost and 

schedule overruns on DOE’s cleanup projects.14 The Council reported that 

research studies suggest that inadequate project definition accounts for 

50 percent of the cost increases for environmental remediation projects. 

Again, no DOE team is specifically examining the “fast-track” approach, 

yet it frequently contributed to past problems and DOE continues to use 

this approach. 

DOE’s efforts to improve its high-level waste cleanup program and to rein 

in the uncontrolled growth in project costs and schedules are important 

and necessary. The accelerated cleanup initiative represents at least the 

hope of treating and disposing of the waste in a more economical and 

timely way, although the actual savings are unknown at this time. 

Furthermore, specific components of this initiative face key legal and 

technical challenges. Much of the potential for success rested on DOE’s 

ability to dispose of large quantities of waste with relatively low 

concentrations of radioactivity on site by applying its incidental waste 

process. Recently, a court ruled that the portion of DOE’s order setting out 

its incidental waste determination process violates the Nuclear Waste 

Policy Act and is invalid. Thus, DOE is precluded from implementing this 

element of its accelerated initiative. Success in accelerating cleanup also 

rests on DOE’s ability to obtain successful technical performance from its 

 13For a discussion of the problems associated with the fast track design/build approach 

on these projects, see U.S. General Accounting Office, Nuclear Waste: DOE’s Hanford 

Spent Nuclear Fuel Storage Project—Cost, Schedule, and Management Issues, 

GAO/RCED-99-267 (Washington, D.C.: Sept. 20, 1999) and Nuclear Waste: Process to 

Remove Radioactive Waste From Savannah River Tanks Fails to Work, GAO-RCED-99-69

(Washington, D.C.: Apr. 30, 1999). 

14National Research Council, Progress in Improving Project Management at the 

Department of Energy (Washington, D.C.: Nov. 2001). 

Conclusions 
Page 21 GAO-03-930T High-Level Waste Cleanup 

as-yet unproven waste separation processes. Any technical problems with 

these processes will likely result in costly delays. At DOE’s Hanford Site, 

we believe the potential for such problems warrants reconsidering the 

need for more thorough testing of the processes, before completing 

construction of the full-scale waste separation facility. 

DOE’s accelerated cleanup initiative should mark the beginning, not 

the end, of DOE’s efforts to identify other opportunities to improve the 

program by accomplishing the work more quickly, more effectively, or at 

less cost. As DOE continues to pursue other management improvements, 

it should reassess certain aspects of its current management approach, 

including the quality of the analysis underlying key decisions, the 

adequacy of its approach to incorporating new technologies into projects, 

and the merits of a fast-track approach to designing and building complex 

nuclear facilities. Although the challenges are great, the opportunities for 

program improvements are even greater. Therefore, DOE must continue 

its efforts to clean up its high-level waste while demonstrating tangible, 

measurable program improvements. 

In the report being released today, we made several recommendations to 

help DOE manage or reduce the legal and technical risks faced by the 

program as well as to strengthen DOE’s overall program management. 

DOE agreed to consider seeking clarification from Congress regarding its 

authority to define some waste as incidental to reprocessing, if the legal 

challenge to its authority significantly affected DOE’s ability to achieve 

savings under the accelerated initiative. Regarding our recommendations 

to conduct integrated pilot-scale testing of the separations facility at 

Hanford before construction is completed, and to make other management 

improvements to address the weaknesses I just discussed, DOE’s position 

is that it has already taken appropriate steps to manage the technology 

risks and strengthen its management practices. We disagree and believe 

that implementing all of our recommendations would help reduce the risk 

of costly delays and improve overall management of DOE’s entire highlevel waste program. 

- - - - - 

Thank you, Mr. Chairman and Members of the Subcommittee. That 

concludes my testimony. I would be pleased to respond to any questions 

that you may have. 
Page 22 GAO-03-930T High-Level Waste Cleanup 

Contacts and Acknowledgements 

For further information on this testimony, please contact Ms. Robin 

Nazzaro at (202) 512-3841. Individuals making key contributions to this 

testimony included Carole Blackwell, Robert Crystal, Doreen Feldman, 

Chris Hatscher, George Hinman, Gary Jones, Nancy Kintner-Meyer, Avani 

Locke, Mehrzad Nadji, Cynthia Norris, Tom Perry, Stan Stenersen, and Bill 

Swick. 

(360365) 
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